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NOV T. 0.2019 UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF LOUISIANA

MONROE DIVISION

UNITED STATES OF AMERICA * CRIMINAL NO.A

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VERSUS **

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DONNIE LAING, JR. *

3:19-cr-00364Judge DoughtyMagistrate Judge Hayes

INDICTMENT

THE GRAND JURY CHARGES:

COUNTS 1-9Wire Fraud

18 U.S.C. § 1343

At all times material to this Indictment:

1. The defendant, DONNIE LAING, JR., was a resident of the Western

District of Louisiana.

2. A Ponzi scheme is a financial fraud whereby an operator induces

investments from individuals (the Ponzi Investors") by promising high investment

returns with little or no risk of loss. In a Ponzi scheme, new investor proceeds are

fraudulently converted to an operator s own personal use and benefit and used to pay

fabricated returns to previous investors, under the guise that such monies represent

1

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legitimate returns on investment. A Ponzi scheme cultivates an illusion that

legitimate profit-making business opportunities exist, thereby inducing further

investment.

3. The Ponzi Investors lived and conducted business primarily in

Northeast Louisiana.

4. Capital Energy Investments (Capital), was a Louisiana limited

liability company, formed on or about February 10, 2017, with a registered address

of 1109 Jules Broussard Road, Breaux Bridge, Louisiana, whose sole member and

registered agent was the defendant, DONNIE LAING, JR.

5. Capital held a business account with Iberia Bank, a regional bank

headquartered in Lafayette, Louisiana and operating in multiple states throughout

the southeast United States.

THE SCHEME AND ARTIFICE TO DEFRAUD

6. Beginning on or before April 16, 2018, and continuing through on or

after November 1, 2018, in the Western District of Louisiana and elsewhere, the

defendant, DONNIE LAING, JR,, did knowingly and unlawfully devise and intend to

devise a scheme and artifice to defraud and to obtain money from multiple investors

by means of false and fraudulent pretenses, representations, and promises. For the

purposes of executing and attempting to execute the scheme and artifice to defraud,

the defendant, DONNIE LAING, JR., aided and abetted by "Individual A" and other

persons both known and unknown to the Grand Jury, did knowingly utilize and cause

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others to utilize interstate wire communication facilities, including bank-to-bank

wire transfers, to send and receive monies representing the proceeds of the scheme

to defraud in violation of 18 U.S.C. § 1343. The scheme and artifice to defraud was

as follows:

7. It was part of the scheme and artifice to defraud that the defendant,

DONNIE LAING, JR., formed a business relationship with "Individual A", an

associate living in northeast Louisiana, who was well-known in the City of Monroe

and throughout northeast Louisiana due to his former position as a United States

Congressman.

8. It was further part of the scheme and artifice to defraud that the

defendant, DONNIE LAING, JR., enlisted the assistance of "Individual A", to solicit

money from the Ponzi Investors to, among other things, invest in Capitals purported

purchase of oil and gas equipment for use in "tracking wells.

9. It was further part of the scheme and artifice to defraud that, in

soliciting these monies, DONNIE LAING, JR. falsely and fraudulently represented

to the Ponzi Investors that he had contracts and relationships with oil and gas

companies that would allow Capital to earn high rates of return by purchasing oil

and gas equipment and then leasing such equipment to oil and gas companies

engaged in oil and gas exploration activities.

10. It was further part of the scheme and artifice to defraud that the

defendant, DONNIE LAING, JR., did not invest any of the money transferred to him

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by the Ponzi Investors into the promised investments. Instead, DONNIE LAING,

JR., used the Ponzi Investors' money for his own purposes.

11. It was further part of the scheme and artifice to defraud that in

executing and attempting to execute this scheme, the defendant, DONNIE LAING,

JR., created and distributed to the Ponzi Investors false and fraudulent proposals,

contracts, and other documents to induce the Ponzi Investors to remit funds to him.

12. It was further part of the scheme and artifice to defraud that the

defendant, DONNIE LAING, JR., provided certain Ponzi Investors with monetary

payments ("lulling payments") that he fraudulently represented were returns on

investment from their alleged investments; knowing instead that these payments

were actually investment monies provided by other Ponzi Investors. In this manner,

DONNIE LAING, JR., funneled new investor funds to previous investors under the

guise of legitimate profits and returns, thereby inducing further investment.

13. It was further part of the scheme and artifice to defraud that the

defendant, DONNIE LAING, JR., wrongfully obtained a cumulative amount in excess

of $1 million from the Ponzi Investors.

14. It was further part of the scheme and artifice to defraud that in

executing and attempting to execute this scheme, the defendant, DONNIE LAING,

JR., utilized and caused others to utilize interstate wire communication facilities,

including email and inter-bank wire transfers as means of communicating with

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Individual A and the victims of the offense, and to send and receive monies

representing the proceeds of the scheme to defraud.

THE CHARGES

14. On or about the dates listed below, in the Western District of Louisiana

and elsewhere, the defendant, DONNIE LAING, JR., having devised and intending

to devise a scheme and artifice to defraud and to obtain money as described above by

means of false and fraudulent pretenses, representations, and promises, and for the

purposes of executing and attempting to execute the above described scheme and

artifice to defraud, did knowingly utilize and cause others to utilize interstate wire

communication facilities, including inter-bank wire transfers and other means, to

send and receive monies representing the proceeds of the scheme to defraud, each

transmission constituting a separate count:

COUNT DATE

April 25, 2018

June 1, 2018

June 7, 2018

DESCRIPTION

Interstate wire transfer of $175,000 fromPonzi Investor to a Capital account at IberiaBank.

Interstate wire transfer of $135,265.50 fromPonzi Investor to a Capital account at IberiaBank.

Interstate wire transfer of $135,265.50 fromPonzi Investor to a Capital account at IberiaBank.

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6

9

June 19, 2018

Sept. 10, 2018

Sept. 12, 2018

Sept. 14, 2018

Sept. 19, 2018

Interstate wire transfer of $325,000 fromPonzi Investor to a Capital account at IberiaBank.

Interstate wire transfer of $100,000 fromPonzi Investor to a Capital account at IberiaBank.

Interstate wire transfer of $130,000 fromPonzi Investor to a Capital account at IberiaBank.

Interstate wire transfer of $70,000 from PonziInvestor to a Capital account at Iberia Bank.

Interstate wire transfer of $100,000 fromPonzi Investor to a Capital account at IberiaBank.

Interstate wire transfer of $45,000 from PonziInvestor to a Capital account at Iberia Bank.

Oct. 19, 2018

all in violation of Title 18, United States Code, Section 1343. [18 U.S.C. § 1343].

A TRUE BILL:

FOREPERSON: FEDERAL GRAND JURY

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